accompanying
statement
explains
how
Toledo
Telenet
Long
Distance
Company’s
operating
procedures
ensure
that
the
company
is
in
compliance
with
the
rules
governing
CPNI
as
found
in
Subpart
U
–
Customer
Proprietary
Network
Information
–
Part
64
of
Title
47
of
the
Code
of
Federal
Regulations.
Toledo
Telenet
Long
Distance
Company
adheres
to
all
CPNI
rules
as
stated
in
section
64.2001
–
64.2011
concerning
the
proper
use
of
our
customer’s
CPNI.
Specifically,
our
notice
for
use
of
CPNI
approval
process
meets
all
requirements
as
listed
in
Section
64.2008.
To
further
protect
our
customer’s
privacy,
we
have
implemented
all
safeguards
required
in
Section
64.2009.
This
includes:
• • • • • • The
implementation
of
a
system
by
which
the
status
of
a
customer’s
CPNI
approval
can
be
clearly
established
prior
to
the
use
of
CPNI;
The
annual
training
of
appropriate
personnel
as
to
when
they
are,
and
are
not,
authorized
to
use
CPNI
and
the
documentation
of
this
training;
The
implementation
of
an
express
disciplinary
process
for
CPNI
violations
up
to
and
including
termination;
The
maintenance
of
a
record,
for
at
least
one
year,
of
our
own,
and
our
affiliates’
sales
and
marketing
campaigns
;
The
establishment
of
a
supervisory
review
process
regarding
carrier
compliance
with
the
federal
CPNI
rules
for
outbound
marketing
situations;
and
The
establishment
of
annual
certification
by
a
corporate
officer
with
personal
knowledge
of
Toledo
Telenet
Long
Distance
Company’s
policies
and
procedures
to
ensure
compliance
with
the
federal
CPNI
rules.
The
establishment
of
procedures
for
notification
of
the
Commission
of
any
instance
where
opt-­‐ out
mechanisms,
do
not
work
properly,
to
such
a
degree
that
consumers’
inability
to
opt-­‐out
is
more
than
an
anomaly.

•

Toledo
Telenet
Long
Distance
Company
has
on
file
with
the
FCC
its
CPNI
Manual,
without
the
sample
Forms,
as
further
detailed
explanation
of
how
its
procedures
ensure
that
it
is
in
compliance
with
the
rules
in
Subpart
U
of
Part
64,
of
Title
47
of
the
Code
of
Federal
Regulations.